Vero Beach Fl Bank with Online Mortgage Application - PDF - PDF by glg77137


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									                                           NOVEMBER 2006

CRA/HMDA Aggregate and                                                                     Census Changes
Disclosure Distribution Changes                                                            As announced by the Office of Manage-
                                                                                           ment and Budget on December 5, 2005,

      he collection of calendar           institutions. Disclosure statements for          Sebastian, FL now qualifies as a new
                                                                                           principal city of the Vero Beach, FL Met-
      year (CY) 2005 Community            each reporting institution and ag-
                                                                                           ropolitan Statistical Area (MSA). Begin-
      Reinvestment Act (CRA), Home        gregate disclosure reports for each              ning with calendar year 2006 data, the
Mortgage Disclosure Act (HMDA),           MSA/MD and non-MSA/MD pre-                       title and MSA code for the Vero Beach,
and Private Mortgage Insurance            pared from the 2005 CRA data are                 FL MSA 46940 revised to Sebastian-Vero
Companies of America (PMIC) data          only available on the web at www.                Beach, FL MSA 42680.
is complete. The 2005 CRA, HMDA  Additionally, the CRA
and PMIC aggregate report tables          flat files that were formerly available          The MSA title and code change will be
and individual lender disclosure          on the CD-ROM product are posted                 reflected on the 2007 FFIEC HMDA
statements are now only available         on the web so that individuals or                (version 3.30) and 2007 CRA Data
from the Federal Financial Institutions   institutions may import the CRA data             Entry Software (version 3.30). Since
Examination Council (FFIEC) via           into software packages for further               the software will be valid for calendar
                                                                                           years 2004-2007 data, users should
The CRA flat files that were formerly available on the CD-ROM                              run the batch edit and error report, both
                                                                                           located on the software application’s
product are posted on the web so that individuals or institutions may
                                                                                           “Front Page” prior to submitting data.
import the CRA data into software packages for further analysis.                           The batch edit feature will display the
                                                                                           total number of LAR records with validity
the Internet at The        analysis. The CRA flat files contain             errors. The error report will identify all
production of the aggregate               the transmittal sheet, aggregate                 LAR records with validity errors when you
tables and individual lender              reports, and disclosure statements,              choose the validity only option. Correct
disclosure reports for all three          and are found at http://www.ffiec.               all validity errors identified on the error
reporting series on CD-ROMs               gov/cra/craflatfiles.htm.                        report prior to submission including all
was discontinued beginning with                                                            loan application records with a property
CY 2005 CRA, HMDA, and PMIC               On September 8, 2006, the FFIEC                  location in the Sebastian-Vero Beach,
data.                                     member agencies – FRS, FDIC, OCC,                FL MSA (i.e., any 2006 loans geocoded
                                                                                           with MSA 46940 must be corrected to
                                          OTS, and National Credit Union
                                                                                           reflect the new MSA 42680.)
On July 25, 2006, four FFIEC agen-        Administration (NCUA) – and the
cies -- the Board of Governors of the     Department of Housing and Urban                  Additional information regarding the
Federal Reserve System (FRS), the         Development (HUD) announced the                  MSA code change can be found on
Federal Deposit Insurance Corpora-        availability of 2005 HMDA data.                  the Statistical Programs and Standards
tion (FDIC), the Office of the Comp-      Financial institution disclosure state-          page on the Office of Management and
                                                                                                                                         1 CRAHMDA Reporter

troller of the Currency (OCC), and        ments and MSA/MD and nationwide                  Budget’s web site (www.whitehouse.
the Office of Thrift Supervision (OTS)    aggregate reports are only available             gov/omb).
-- announced the availability of 2005     on the FFIEC web site at www.ffiec.
CRA data as reported by certain           gov/hmda. (The HMDA Loan Ap-
commercial banks and savings                                            contiued on p. 6
Type of Purchaser (TOP) Coding Issues                                         Easy ways to search the
                                                                              HMDA Guide online

      he type of purchaser (TOP) field on the HMDA-LAR identifies the
      type of secondary market entity that originated or purchased loans
      were sold to within the same calendar year. We have revised or            While it is advisable to print
expanded some of the entity types that an institution may sell these          the document in order to have
loans to; for example, private securitization (code 5), mortgage bank          a paper copy on hand, there
(code 7) and finance company (code 7). We have also included spe-             are several useful advantages
cific questions and answers about when to use these codes at the fol-         to using the electronic version
lowing web site ( These FAQs                 of the HMDA Guide.
are worth reading and familiarizing yourself with accurate reporting of
the TOP field.                                                                The updated 2006 version of A
                                                                              Guide to HMDA Reporting: Get-
It is important that your institution be prudent in selecting the correct     ting it Right is now available ex-
code for loans that are sold within the same calendar year. A report-         clusively on the web (http://www.
ing problem was uncovered in the 2005 data during the data quality  
assessment period whereby a couple institutions should have reported          pdf). While it is advisable to print
their sold loans using a TOP code of 5 and not 3. They did not sell           the document in order to have a
directly to Freddie Mac; they sold to an institution that securitized the     paper copy on hand, there are
loans and one of the purchasers of the securitized loans was Freddie          several useful advantages to us-
Mac, which caused the reporting institutions to think that they sold the      ing the electronic version of the
loans to Freddie Mac. However, that was not the case and their data           HMDA Guide.
were corrected.
                                                                              • The ‘Bookmarks’ tab on the left
Other important reminders regarding the reporting of TOP:                       side of the screen provides a
                                                                                view of the overall organization
  Report zero (0) in the TOP field in the following situations:                 of the document and convenient
                                                                                one-click access to a desired
  • Loan was originated but not sold in the calendar year covered by            section.
    the HMDA-LAR activity year;
                                                                              • The search function (obtained
  • Loan was purchased from another entity but not sold in the calen-           by clicking the binoculars icon
    dar year covered by the register; or                                        or right click ‘Search’) allows
                                                                                the user to investigate a specific
  • Application was denied, withdrawn, approved but not accepted by             search criterion. This search
    the applicant; or closed for incompleteness.                                method is effective because a
                                                                                search window appears and
  If you sell loans to more than one purchaser, use the code for the            displays the total search results
  entity purchasing the greatest interest.                                      accompanied by the page num-
                                                                                ber and subject context.
  If you sell only a portion of the loan, retaining a majority interest, do
  not report the sale.                                                        • The final search method is ‘ctrl-
                                                                                f’ which manually takes the user
  If you sell originated or purchased loans at a later time in the same         from one key word to the next
  calendar year covered by the HMDA-LAR activity year, collect the              throughout the document.
  TOP information and update the field on your HMDA-LAR to reflect
  the sale of the loans; also make sure that the correct TOP data are         Please familiarize yourself with this
  submitted in your file.                                                     material. After all, most inquiries
                                                                              from the public to HMDAHELP or
  If you sell originated or purchased loans in a succeeding year, do          the HMDA assistance lines are an-
                                                                                                                      2 CRAHMDA Reporter

  not report the loan sale on that year’s LAR. Additionally, do not go        swered by analysts whose primary
  back and update the TOP column on the LAR for the year in which             resource is the Guide itself. Be-
  the loans were originated or purchased; in this case the type of pur-       come your own HMDA expert by
  chaser will never be reported.                                              learning how to effectively navi-
                                                                              gate the HMDA Guide!
   FFIEC Geocoding/Mapping System                                                    CRA Regulation Changes

        re you receiving an Address        uses to map street addresses is cur-      In August of 2005, the Federal Re-
        Not Found when attempting          rent only to certain dates, and street    serve Board, the FDIC, and the OCC
        to retrieve the Metropolitan       addresses added after that date will      collectively raised the asset thresh-
Statistical Area/Metropolitan Division     not be located. Even after a new          old for large institutions from $250
(MSA/MD), State, County, and Cen-          update is received, it is possible that   million to $1 billion (70 FR 44256).
sus Tract combination from the FFIEC       an address will not be included in the    This follows a similar regulatory
Geocoding/Mapping System (The              database and thus geocoding infor-        change implemented by the OTS in
System)? If so, make sure you are          mation will not be found. In these        2004. Institutions not meeting the
following the system requirements.         cases, you should use census tract        new large institution asset threshold
                                           maps and other tools available from       requirements are no longer obligated
The System allows you to retrieve          the U.S. Census Bureau.                   to report their annual CRA data to
MSA/MD, State, County and Census                                                     the Federal Reserve Board. In addi-
Tract combinations for street ad-          When an address is not found, use         tion, the holding company affiliation
dresses. It is primarily intended to       the mapping feature. The System           is no longer a factor in determining
assist financial institutions covered by   will display an area street map based     whether an institution is required to
the Home Mortgage Disclosure Act           on the combination of street address      submit CRA data.
(HMDA) and Community Reinvest-             and zip code, OR street address, city
ment Act (CRA) to meet their report-       and state. A red triangle will mark       Institutions that do not meet the new
ing obligation. The system is also         the center of the zip code area on the    asset criteria of large institutions still
helpful in obtaining census demo-          map (not the location of the prop-        have the option of reporting CRA
graphic information on population          erty). Click on the map and zoom          data on a voluntary basis. Those
and income data.                           in/out to locate the cross streets for    institutions, who submit their CRA
                                           the address and identify a census         data to the Board by the March 1st
To render a successful result, you         tract code. The mapping feature           deadline, retain the option of being
must enter a street address along          may not appear in all cases. For          examined as a large institution even
with a city and state OR a zip code.       example, if you enter an invalid state    if they did not meet the asset thresh-
All four fields do not need to be com-     and zip code combination or an in-        old of $1 billion. However, by not
pleted; however, the street address        valid city and state combination, you     reporting CRA data by the March 1st
must be entered and accurate. For          will receive an Address Not Found         deadline, an intermediate or small
example, if the address includes the       with no mapping feature available.        institution sacrifices the option of be-
word “street,” use that word; do not                                                 ing examined as a large institution.
enter the address using words like         It is critical that you follow The Sys-
“avenue” or “boulevard.” Also, do          tem requirements to prevent prop-
not include apartment numbers with         erty location validity errors on your           For additional information on the
the street number and address. The         HMDA report. If the FFIEC Geo-                 regulation changes please visit the
correct city and state OR zip code         coding System does not provide the                    following web page.
should be included for the street ad-      geographical information about the 
dress. The System will not geocode         property location, there are several        2422/01jan20051800/edocket.access.
P Boxes or Rural Routes. Once              other tools that can be used (refer to 
you have entered the correct address       pages 18-21 of the Guide to HMDA
information in the appropriate boxes,      Reporting: Getting it Right!) to geo-         For additional information regarding
click on the ‘Search’ button to obtain     code your data. It is the institution’s      CRA examination procedures of small,
the geocoding information.                 responsibility to exhaust all available        intermediate, and large institutions
                                           resources to obtain valid property           please go to the following web page.
The System may not provide prop-           location information. In any case,
erty location information for all valid    if your institution has exhausted all
street addresses. While this should        your resources and questions re-
                                                                                                                                   3 CRAHMDA Reporter

                                                                                       For other CRA-related inquiries, please
not occur often, it is normal because      main, please feel free to contact             contact the CRA Assistance Line at
the geocode database that the FFIEC                            (202)872-7584, or send an email to
HMDA Data Entry Software Version 3.30
HMDA Data Entry Software Version              Version 3.30 for CY 2007 data col-              Beginning with calendar year 2006
3.30, for the collection and report-          lection contains several 2006 edit              data, the title and MSA code for the
ing of CY 2004 through CY 2007                updates which are listed below. All             Vero Beach, FL MSA 46940 revised
data, is scheduled for release in             users should download the most                  to Sebastian-Vero Beach, FL MSA
December 2006. Version 3.30 will              current version in order to reflect all         42680 (Refer to Census article in
only be available by download from            updates in your 2006 HMDA submis-               this newsletter). Run an error report
the FFIEC web site (http://www.ffiec.         sion file. Your HMDA data must be               and correct all loan application re-
gov/software/default.aspx). The free          edited prior to submission using the            cords with a property location in the
software includes editing features to         FFIEC HMDA edits (http://www.ffiec.             Sebastian-Vero Beach, FL MSA (i.e.,
help you verify and analyze the ac-           gov/hmda/edits.htm). Regulation C               any 2006 loans geocoded with MSA
curacy of the reporting data.                 requires all HMDA data submissions              46940 must be corrected to reflect
                                              to be free of validity errors prior to          the new MSA 42680.) Utilize the
The data file created using the               submission. You must submit a valid-            Global Modify feature located under
FFIEC software must be encrypted              ity-free submission or your institution         the Edit Menu on the Front Page of
for submission via Internet e-mail or         is at risk of noncompliance.                    the software. See Help for more
exported onto a diskette/CD-ROM                                                               details.
for mailing.

Deleted Edits                                                         END-OF-CYCLE Macro Quality Edits (CONT’D)
V405   Replaced with Q059 (See New Edits).                            Q056 Checks that the total number of denied conventional home
V380   Replaced with Q060 (See New Edits).                                 purchase loans is ≤ 70% if the total number of conventional
                                                                           home purchase loans is ≥ 50.
New Edits                                                             Q057 Checks that the total number of denied loan applications
Q050 Checks for valid HOEPA status code is Agency = 5 (NCUA).              is > zero if the total number of loan applications is ≥ 50.
Q051 Checks for valid HOEPA status code when applicant ethnicity,     Q058 Checks that the total number of preapproval requests denied
     race and sex = 4, 7, and 4 respectively.                              is > zero if the total number of loan applications where
Q052 Checks for valid HOEPA status code when property type = 3.            preapproval = 1 is ≥ 1000.
Q059 Checks for valid property type if loan type = 3 or 4.            Q061 Checks that the total number of originated loans (action taken
Q060 Checks for valid date application received.                           type =1) where property type = 1, lien status = 1, and rate
Q061 Checks for valid rate spread when Agency = 5 (NCUA),                  spread > 5% and not = NA is ≤ 1% of the total number of
     property type = 1, lien status = 1, and action taken type = 1.        originated loans. (Note: End-of-Cycle Macro Edit Q061
Q062 Checks for valid HOEPA status when action taken = 1,                  includes Agency 1, 2, 3, 4, 5, and 7)
     HOEPA status = 1, lien status = 1 and purchaser type = 1.        Q062 Checks that the total number of originated loans (action taken
Q063 Checks for valid HOEPA status when action taken = 1,                  type = 1) where HOEPA status = 1, lien status = 1 and
     HOEPA status = 1, lien status =1 and type of purchaser = 3.           purchaser type = 1 is ≤ 1% of the total number of originated
END-OF-CYCLE Macro Quality Edits                                      Q063 Checks that the total number of originated loans (action taken
Q053 Checks that the total number of originated loans (action taken        type = 1) where HOEPA status = 1, lien status = 1 and
     type = 1) where agency = 5 and HOEPA status = 1 is ≤ 1%               purchaser type = 3 is ≤ 1% of the total number of originated
     of the total number of originated loans.                              loans.
Q054 Checks that the total number of purchased loans (action taken
     type = 6) where agency = 5 and HOEPA status = 1 is ≤ 1%          Revised Edits
     of the total number of purchased loans.                          Q030   Edit test modified to remove CRA asset test.
Q055 Checks that the total number of originated loans (action taken   S100   Edit test language modified to check for valid activity year.
     = 1) where HOEPA status = 1 and rate spread ≥ 5% and             Q044   Edit test modified to exclude Agency 5.
     not = NA, is ≤ 5% of the total number of originated loans.       Q045   Edit test modified to exclude Agency 5.

In addition, if you utilize third-party       HMDA Data Entry Software by using               option for submitting your HMDA
vendor software for HMDA data                 the editing and reporting features.             data. Submit your 2006 valid en-
                                                                                                                                             4 CRAHMDA Reporter

collection and reporting, you should                                                          crypted HMDA data file via e-mail
take advantage of the benefits of the         Sending your submission via Internet            to on or before
                                              e-mail remains the most efficient               March 1, 2007.
Relieve Stress & Increase Efficiency - -
Submit via Internet E-mail

    oe and Mary are siblings as          (2) Import (or manually enter) the        Board prior to the specified due
    well as bankers who both                 HMDA data into the DES;               date. It is now March 1st and
    filed their bank’s HMDA-LAR          (3) Perform a batch edit to identify      Mary is leaving early for the day.
on February 26th, just shy of the            any validity errors and qual-
March 1st due date; however,                 ity edits; (All data with validity    For Joe, however, life is not so
the similarities end here. You               errors must be corrected prior        easy. Delayed by additional post-
see, Joe filed his HMDA data                 to submission; data with qual-        al security checks, his paper copy
the same way he always has--by               ity edits should be verified and      submission has not yet arrived at
submitting a hand-written paper              corrected if necessary)               the FRB’s HMDA Operations of-
copy via postal mail without using       (4) Export/create an encrypted file       fice. Even though his submission
the HMDA Data Entry Software                 submission (hmdaencr.enc);            will be on time because it was
(DES). Mary, in contrast, decided        (5) E-mail to             postmarked prior to the March
she would try the recommended                                                      1st deadline, Joe is worried that
method of submitting her report          Shortly after submitting the              his submission has not yet arrived
via e-mail. This was the first           HMDA-LAR via e-mail, Mary                 (unlike Mary, he receives no im-
year Mary decided to follow the          receives an e-mail response               mediate confirmation of receipt).
five simple steps of submitting          confirming the receipt of her             Furthermore, there is a possibility
electronically:                          submission. Upon receiving her            that he will have to correct data
                                         edit report, Mary again checks the        containing validity errors on an
(1) Download the free FFIEC              accuracy of the data containing           edit report that should be sent to
    HMDA Data Entry Software             quality edits, signs and dates the        him at a future date. After all, he
    (DES),         confirmation sheet, and faxes the         did not run the data through any
    hmda/softinfo.htm;                   required documentation to HMDA            edits.
                                         Operations at the Federal Reserve

The moral of this story is that when done properly, submitting via Internet e-mail is the best way to go!
Here are some of the excellent reasons why…

10   No calls/trips to the mail carrier to overnight the diskette/CD-ROM or paper copy reports.
 9   No shipping/postage fees.
 8   No sleepless nights wondering if the bank’s HMDA report was lost in the mail.
 7   No additional trips to the mail carrier to overnight resubmissions or missing
 6   Immediate confirmation that the submission has been received.
 5   Quicker turn-around for edit reports/corrections.
 4   No lost or damaged diskettes/CD-ROMs or paper copy reports.
 3   Validity error-free data are submitted--Data must contain no validity errors before the
     DES software will allow the encrypted ENC file to be created and sent via Internet e-mail.
 2   Everybody’s doing it! (Over 95% of reporters submitted via Internet e-mail during the
     calendar year 2005 data processing season)

And the Number ONE reason for submitting via Internet e-mail is...
                                                                                                                         5 CRAHMDA Reporter

1 E-mails are the most efficient method—the encrypted ENC file is received via
  e-mail, reviewed and usually loaded within the same day.
  contiued from p. 1

plication Register (LAR) & Transmittal   statement available at one branch      at (The
Sheet (TS) raw data product, howev-      per MSA or provide a copy upon         PMIC LAR and TS raw data product
er, continues to be available on CD-     written request.                       is available on CD-ROM; for product
ROM. For availability of this product                                           availability and ordering instructions,
and to order it from the FFIEC, refer    The FFIEC also provides PMIC data      refer to
to         collected from the nation’s eight      form.htm).
htm)).                                   private mortgage insurance compa-
                                         nies. The PMIC data include infor-     If you have any questions about
Financial institutions are required      mation on applications for mortgage    an aggregate or disclosure report,
to make their disclosure statements      insurance. The 2005 PMIC disclo-       please e-mail us at hmdahelp@frb.
available at their home offices; and,    sure statements and MSA/MD and         gov.
for other MSAs in which they have        nationwide aggregate reports are
offices, to either make a copy of the    only available on the FFIEC web site

                                                                                   NEED ASSISTANCE?

                                FFIEC                                              For further assistance with CRA and
                                                                                 HMDA, visit the following web sites, send

                                                                                  an e-mail, or call the phone numbers
                                                                                               listed below:

                              R E S O U R C E S                               
                                                                                             (202) 872-7584
          Below is a list of the more popular FFIEC reporting
           publications and filing resources available on the                                   HMDA
                   FFIEC CRA and HMDA web sites.                                
                                                                                            (202) 452-2016

                        CRA                          HMDA
             CRA Aggregate Reports              HMDA Aggregate and
                                                 Disclosure Reports
                                                                                 Revised 2005 HMDA
             CRA Disclosure Reports
                                                                                 Disclosure Statement
                                          Frequently Asked Questions (FAQs)
   Interagency Questions & Answers
                                           FFIEC HMDA Data Entry Software        2005 HMDA resubmissions warranting
      FFIEC CRA Data Entry Software                                              a revised disclosure statement will be
                                               FFIEC Geocoding System            accepted up to February 27, 2007.
           FFIEC Geocoding System                                                We strongly recommend that institutions
                                             FFIEC Rate Spread Calculator        e-mail their HMDA resubmissions to
                       How to File                                      for expedited
                                                      How to File                processing. Institutions will receive a
                                                                                                                              6 CRAHMDA Reporter

                   Where to Submit                                               2005 Edit Report for their review and
                                                                                 confirmation. A revised copy of the dis-
                                                   Where to Submit
                                                                                 closure statement will be provided to the
                                                                                 institution. Resubmissions of 2005 data
                                                                                 received after this date will be processed
                                                                                 but a revised disclosure statement will
                                                                                 not be available.
Mergers and Acquisitions:                                                              CRA Data Entry Software
How and when to report HMDA data                                                       The next scheduled release of the
                                                                                       FFIEC CRA Data Entry Software, Ver-
If your institution was involved in a structure change: i.e., a merger or acqui-       sion 3.30, will be available for down-
sition, there is a good chance that change may affect how and when your                load from the FFIEC CRA web site in
institution should report their HMDA data. In any case, you should contact             Fall 2006. The software is free and and inform them of the change, and how you will submit                can be utilized for editing, reporting,
your HMDA data for the year of the merger and subsequent years. Below are              and submission purposes.
five examples of situations that may occur.
                                                                                       Additionally, several software fea-
  Two institutions merge, producing a successor institution whose assets               tures may be useful in the process of
  exceed the asset threshold for coverage. Both were previously exempt                 collecting and reporting CRA data.
  because of asset size. The successor institution’s first HMDA data collection        These include data quality checks,
  will be for the calendar year following the year of the merger. No data col-         analysis reports, and optional loan
  lection is required for the year of the merger.                                      categories that institutions may use in
                                                                                       collecting data for consideration in a
  Two institutions merge, one covered and one exempt. The covered insti-               CRA exam.
  tution is the surviving institution. For the year of the merger, data collec-
  tion for loan applications, originations, and purchases is required for the          Version 3.30 will also include an
  covered institution’s transactions and is optional for transactions handled in       enhancement to the Batch MSA/MD
  offices of the previously exempt institution.                                        Change feature in the Edit func-
                                                                                       tion. This feature will enable users to
  Two institutions merge, one covered and one exempt. The exempt institution           update an MSA/MD code for multiple
  is the surviving institution, or a new institution is formed. Data collection for    loan application registers (LARs) in a
  loan applications, originations, and purchases is required for transactions of       single screen. With the older versions
  the covered institution that take place prior to the merger. Data collection is      of the software, users had to manually
  optional for transactions taking place after the merger date.                        update the MSA/MD code on every
                                                                                       applicable LAR, a potentially time-
  Two covered institutions merge. The surviving or resulting institution must          consuming effort. However, with this
  report complete data for the year in which the merger occurred; the institu-         enhanced feature, users would use a
  tion has the option of filing a consolidated report or separate reports for          four-step process to revise or update
  that year.                                                                           an MSA/MD code across multiple
  • If the institutions reported to different agencies before the merger, the re-      1. From the Edit menu on the CRA
    ports for the year in which they merged and all subsequent reports must               Front Page, click on Batch MSA/
    be submitted to the agency designated by the supervisory agency of the                MD Change
    surviving or resulting institution to receive that institution’s data.             2. Check the box next to “Change
                                                                                          Specific MSA/MD?”
     If the surviving covered institution is regulated by an agency different from     3. Input both the old and new MSA/
     the agency regulating the covered non-survivor, and the surviving institu-           MD codes in the appropriate boxes
     tion chooses to file separate reports, the surviving covered institution files    4. Click Begin
     their report using their specific respondent ID number and agency code.
     However, the surviving institution uses an altered RID number along with the      The software will then replace the
     survivor’s agency code when filing the non-survivor’s report. The non-sur-        old code with the new one in all of
     vivor’s old RID number is altered by replacing the leading three zeros with       the applicable LARs. For example, if
     “99-“. This identifies that the data is from a non-survivor filing separately.    a user has small business and small
                                                                                       farm LARs in their data entry software
  In the situation where neither a merger with nor an acquisition of an institu-       system that are geocoded with the old
  tion, nor an acquisition of a branch, is involved, and the covered institution       MSA/MD code for Vero Beach, FL
  purchases HMDA-related loans in bulk from another entity (for example,               (46940), they can use this enhanced
  from a failing institution), the purchasing institution must report those loans      feature to revise their LARs to reflect
                                                                                                                                 7 CRAHMDA Reporter

  as “purchased loans.”                                                                the new MSA/MD code for Sebas-
                                                                                       tian–Vero Beach, FL (42680). [This
This list of situations is not all inclusive; if your institution has a specific ex-   code change was announced by the
ample and would like guidance, please feel free to contact hmdahelp@frb.               Office of Management and Budget on
gov.                                                                                   December 5, 2005].
Resubmitting HMDA Data Guidelines                                                        What is an Agency Code?
                                                                                         An agency code is a one-digit number
An institution is expected to submit valid and accurate HMDA data that have been
                                                                                         that represents the regulatory agency that
checked using edits approved for the particular calendar year. Effective January 1,
2006, a processing procedural guideline was changed with regards to complete             supervises your institution. The codes
resubmissions. If an institution is to resubmit its data, it should send a complete      are as follows:
resubmission; it should not send partial resubmissions. A couple exceptions to the       Office of the Comptroller
rule are:                                                                                of the Currency (OCC)                    1

                                                                                         Federal Reserve System (FRS)             2
LAR count is greater than 350,000 records
Institutions that submit HMDA-LAR containing more than 350,000 records may               Federal Deposit Insurance
request a maximum of 10 manual corrections via fax, e-mail, or telephone, per            Corporation (FDIC)                       3
submission. If a subsequent edit report from a file requires more than 10 corrections,   Office of Thrift Supervision (OTS)       4
the institution should send a complete resubmission.
                                                                                         National Credit Union
                                                                                         Administration (NCUA)                    5
Paper submission with 25 or fewer LAR records
A HMDA-LAR submitted on paper is accepted from institutions reporting 25 or fewer        Department of Housing and
loan records. If 10 or fewer errors are found in the edit report of a paper submis-      Urban Development (HUD)                  7
sion, the institution may request manual changes via fax, e-mail, or telephone. If the
subsequent edit report from a paper submission contains more than 10 corrections,        What is a Respondent Identification
the institution should send a complete resubmission.                                     (RID) Number?
                                                                                         A RID number is a ten-digit number;
If you are resubmitting, then, after you correct your data, follow the same steps you    the numbers for depository institutions
would in creating your initial submission (batch edit, export data, transmit data, re-   require leading zeros to meet the length
ceive and resolve edit report, and sign off on the confirmation sheet).
                                                                                         requirement. The RID number is derived
                                                                                         from different agency identifiers. A RID
Transmit the entire corrected file via Internet e-mail, CD-ROM, or diskette. Clearly
mark your resubmission as a “Complete Resubmission of CCYY data.” Also include           number, along with the agency code,
the reason for your resubmission along with the other information asked for in the In-   ties the number to a specific agency and
ternet e-mail, diskette, or CD-ROM file specifications (for example, institution name,   institution. The identifiers for depository
respondent ID number, agency code, processing year, contact name, phone number,          institutions include:
LAR count being transmitted).                                                            OCC    -   charter number
                                                                                         FRS    -   RSSD number
Reasons for a resubmission include changes to: LAR count; MSA/MD; respondent             FDIC   -   certificate number
name; RID number and/or agency code; loan type; property type; loan purpose;             OTS    -   docket number
10% or more of data, 100 or more records, etc. It is also helpful if you include         NCUA   -   charter number
whether the changes resulted from an internal audit or an exam.
                                                                                         The identifiers for nondepository
If you choose the Internet e-mail option to transmit your data, send a complete resub-   institutions include:
mission to If you choose the diskette or CD-ROM option, mail            FDIC, OCC and NCUA - federal tax ID number
(preferably overnight) the file to:                                                         with the hyphen
                                                                                         OTS - federal tax ID number without the hy-
Federal Reserve Board                                                                       phen and with a leading zero
Attention: HMDA Processing, (Enter Agency OCC, FDIC, OTS, NCUA or HUD)                   FRS - RSSD number
20th and Constitution Avenue, NW                                                         HUD - federal tax ID number with the hyphen
MS N502
                                                                                         In addition to including your RID number
Washington, DC 20551-0001
                                                                                         and agency code on your transmittal
FRS resubmission addresses are available at           sheet, input them in the subject line of
                                                                                         your email (or on your diskette) when
If the resubmission is received after the databases are closed for the annual disclo-    submitting HMDA data. If you have
sure and aggregate reports generation, the resubmitted file is processed when the        reported in the past, please continue to
databases reopen (usually during late June/early July). If the resubmission covers the   use your assigned RID unless otherwise
                                                                                                                                       8 CRAHMDA Reporter

current activity year being processed and your disclosure statement is re-created, the   instructed by HMDA Operations staff.
disclosure statement will be re-created and mailed to you for public disclosure after    If a merger or acquisition occurred re-
the current activity year’s HMDA data are released to the public (usually occurs in      cently and you are unsure about the RID
early September). The publicly-released versions of the disclosure statement found       number and agency code to use, e-mail
on the FFIEC HMDA web site cannot be updated. In addition, the HMDA Raw Data
                                                                                with details.
Software on CD-ROM cannot be updated.
Phases of Editing
Micro, Macro, End-of-Cycle, Data Quality Assessment
Each year, prior to the public release    and resolved as needed. The data          rect, the records should be corrected
of HMDA data, a series of edits are       with validity edits should have been      and a complete resubmission should
performed to ensure data quality,         corrected. Therefore your review of       be sent within a few business days.
integrity and accuracy of reporting.      the edit report documents, and the        Although the timeframe to respond
Your data are run against the HMDA        completion and faxing back of the         to these edits is short, it is reasonable
edits several times from January 1 (if    necessary documents and confirma-         because institutions are expected to
you submit your data that early) and      tion sheet can generally be complet-      know their data with respect to all
mid- to late May.                         ed the same day that the edit report      HMDA edits.
                                          was faxed.
Micro Editing -- A full description of                                              Data Quality Assessment Editing –
the edits including the edit test and     Macro and End-of-Cycle Editing –          The fourth and final phase of edit-
error explanation is available in the     The edit document includes macro          ing occurs over the first three weeks
HMDA edit document, http://www.           quality edits and end-of-cycle qual-      in May during the data quality The             ity edits, which are considered the       assessment period. Other agency
document contains numerous trans-         second and third phases. An institu-      economists, researchers, and analysts
mittal sheet and loan/application         tion’s entire LAR file must be received   generate reports and complete com-
record “micro” edits. These edits         before these macro edits can be           parisons of current to previous years’
are included in the FFIEC Data Entry      performed because we compare cur-         data. Loans sold to the secondary
Software (DES), http://www.ffiec.         rent and previous years’ totals and       market, pricing data, HOEPA and
gov/hmda/softinfo.htm, as well as         percentages, or current year’s total      lien status information are among
in the FFIEC mainframe database           LARs against the number of loans          some of the areas that are checked
editing program. Thus, your data          where a particular action was taken,      again. If institutions are to be con-
goes through the same edits when          type reported, or purpose reported.       tacted, they will be called; immediate
it is loaded to the FFIEC mainframe       For example, a few areas we check         attention and resolution is requested.
database. Following the process-          are:                                      If a corrected resubmission is neces-
ing, an edit report is faxed to you for                                             sary, the resubmission should be sent
review and resolution.                    • Current year’s number and per-          in 1-2 business days.
                                            centage of loans sold to the sec-
By adding these edits to the FFIEC          ondary market in comparison with        These four phases of editing continue
DES, it provides you with a way to          previous year sales;                    to be necessary. For the past sev-
easily check your HMDA-LAR us-            • Income and loan amounts for pat-        eral years we have identified a small
ing edits approved for the particular       terns of possible incorrect report-     number of institutions in the fourth
calendar year and meet the FFIEC’s          ing; and                                editing phase whose data was incor-
expectations of your institution sub-     • Number or percentage of denials         rectly reported. The edit document
mitting valid and accurate data. The        reported based on the total LARs        changes a bit every year. Familiarize
batch edit function on the software         reported.                               yourself with the edit tests and error
allows you to review and correct your                                               explanations of the micro, macro,
data prior to submission. (Data with      The results of the macro editing and      and end-of-cycle edits. Check your
validity errors must be corrected;        end-of-cycle reports are analyzed to      HMDA data against the edits ap-
data with warnings -- quality edits       determine the institutions that should    proved for the particular calendar
-- should be reviewed and corrected,      be contacted based on other factors       year to ensure that you are submit-
if necessary).                            such as institution size, institution     ting valid and accurate data.
                                          location, how large the tolerances
Another advantage to using the DES        are, etc. These two editing phases        We hope this article provides insight
batch edit function is that when the      are usually performed in late March       to the complete HMDA editing pro-
                                                                                                                                9 CRAHMDA Reporter

edit report is faxed to you after your    through April. Institutions are con-      cess, and in case HMDA staff con-
data have been loaded to the FFIEC        tacted by HMDA processing staff via       tact your institution in April or May
database, the only edits that should      faxes, e-mails, and telephone. If the     requesting a “quick” data review and
appear on the edit report are qual-       data are valid, a brief explanation       response, you will be able to respond
ity edits that you already reviewed       is requested. If the data are incor-      quickly.

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